The Certification Commission for Health Information Technology ® (CCHIT), a nonprofit organization in Chicago that offers acceleration of Health IT adoption through certification processes, has submitted comments on the Office of the National Coordinator's January 13 Interim Final Rule on standards and certification criteria for electronic health record (EHR) technology. CCHIT will be presenting discussion of certification issues in an online "Town Hall" meeting this week.

In its comments, CCHIT highlights three areas of concern--scope, interoperability and functionality. For scope, CCHIT says that the requirements for EHRs may not "match the needs and expectations of doctors and hospitals, nor the realities of the marketplace." CCHIT points out that the scope of the criteria should include electronic management of progress notes, and prominently display patient advance directives in an emergency. In addition, by including electronic checking of insurance eligibility and claims submission as administrative functions in the complete EHR criteria, the IFR presents barriers for vendors who have products focusing on clinical information management rather than financial systems. CCHIT recommends dropping this criteria from the Final Rule or making these modules optional, as the Centers for Medicare and Medicaid Services and state Medicaid programs have existing mechanisms to handle claims submission.

Regarding interoperability, CCHIT comments that previous standards for receiving electronic laboratory results and specific implementation guidance for exchanging clinical data (currently recognized by both government and industry) have been dropped in the IFR in favor for two other, incompatible standards. Other criteria including the capability of EHRs to transmit bio-surveillance data to public health authorities have the potential to increase EHR cost and complexity "while benefits remain years away because public health authorities lack standards-compliant infrastructure and systems for receiving that data."

For functionality, CCHIT says certain IFR criteria that define required EHR functionalities are too specific, complex, and present barriers to innovation. Other criteria are too vague to be reliably verified by testing processes. An example is the area of medication reconciliation, wherein the IFR meaning of items on a medication list does not have a defined standard. "Careful human review and interpretation are essential to medication reconciliation, and push-button automation can create a patient safety hazard," CCHIT notes. CCHIT recommends that the criterion should be changed to: Electronically display patient medication information from two or more sources, and allow the user to create or update the patient's medication list based on a review and reconciliation of that information.

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